10 key points affecting Mexico in the draft of the new Chapter VI of the OECD TP Guidelines, pertaining to intangibles

The OECD published a draft of the new Chapter VI of OECD Transfer Pricing Guidelines in June 2012. In general, these transfer pricing guidelines must be applied for Mexican transfer pricing purposes once they are formally approved, unless Mexico expresses an observation. Historically, the guidelines are not materially modified upon issuance of the final report, therefore, multinationals and transfer pricing professionals should be keenly evaluating its potential effects in Mexico.